Privacy policy

PERSONAL INFORMATION COLLECTION STATEMENT

This Statement sets out the basis for how Chocolate Finance HK Limited, a company incorporated in Hong Kong having its registered office at 05-108, The Quayside, 77 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong (the “Company”), collects personal data from the Client (the “User”) in accordance with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”).

By visiting our website www.choloate.com.hk (the “Site”) and/or using our application Chocolate HK (the “APP

1. Collection of Information and Duration of Use

1.1 For the purposes outlined in Clause 2, the Company may collect and process the following information about the User:

1.1.1 Information the User gives the Company - information that the User provides the Company (which may include the User’s name and email address) by filling in forms on the Site and/or the APP, or by corresponding with the Company (by phone, email or otherwise), for example:

(a) when the User reports any problem to the Company;

(b) when the User uses certain features on the Site and/or the APP;

(c) when the User requests any support from the Company;

(d) when the User completes any survey or questionnaire the Company sends the User; or

(e) when the User opens an Account with the Company.

1.1.2 Information the Company collects about the User - information automatically collected when the User visits the Site and/or the APP, for example:

(a) Technical information, including the Internet protocol (IP) address used to connect the User’s computer to the Internet and the log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(b) Information about the User’s visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Site and/or the APP (including date and time), products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the Company; and

1.1.3 Information the Company receives from third parties - the Company works with third parties and may receive information about the User from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. The Company will notify the User when the Company receives information about the User from them and the purposes for which the Company intends to use that information.

1.2 The Company shall store the User’s data for no longer than required under the rules, regulations, and laws of all relevant regulators.

2. Use of Information Gathered

2.1 The Company uses information held about the User for the following purposes:

2.1.1 providing, improving and developing the Company’s services;

2.1.2 researching, designing and launching new features or products;

2.1.3 presenting content and information in the Site and/or the APP in the most effective manner for the User and for the device the User uses;

2.1.4 providing the User with alerts, updates, materials or information about the Company’s services or other types of information that the User requested or signed up to;

2.1.5 responding or taking part in legal proceedings, including seeking professional advice;

2.1.6 for direct marketing purposes (please see further details in Clause 2.2 below);

2.1.7 processing the User’s Account opening application;

2.1.8 carrying out new or existing customer identity verification and assisting other financial institutions to do so;

2.1.9 ongoing Account administration, including the collection of amounts due, enforcement of security, charge or other rights and interests;

2.1.10 comparison with the Customer's personal data (irrespective of the purposes and sources for which such data were collected, and whether collected by a User or any other person) for the purpose of: (A) credit checking; (B) data verification; and/or (C) otherwise producing or verifying data which may be used for the purpose of taking such action that a User or any other person may consider appropriate (including action that may relate to the rights, obligations or interest of the Customer or any other person);

2.1.11 providing on the terms of any other agreements and services relating to the Customer;

2.1.12 any purpose relating to or in connection with compliance with any law, regulation, court order or order of any regulatory body;

2.1.13 investigating suspicious transactions;

2.1.14 any other purpose relating to the execution of a customer's Instructions or in connection with the business or dealings of the Company;

2.1.15 disclosing and transferring the Users personal data (including CID and BCAN(s)) to the SFC and SEHK and any other party involved in accordance with the rules and requirements of SEHK and the SFC in effect from time to time;

2.1.16 communicating with the User and responding to the User’s questions or requests; and

2.1.17 purposes directly related or incidental to the above.

2.2 The Company intends to use the User’s personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to the User). The Company requires the User’s consent specifically for this purpose and the User may opt out at any time. For the purpose of this clause:

2.2.1 the personal data that may be used in direct marketing are those that the User provides to the Company or is collected from the User under Clause 1.1 above;

2.2.2 the type of services or products that may be offered or advertised will be the Company’s products or services, seminars, conferences or events, and those of the Company’s affiliates or business partners;

2.2.3 the relevant information may be sent to the User by email, in-app message or phone call;

2.2.4 the User may opt out at any time by emailing the Company at dummy@chocfin.com. The Company will cease to send the User marketing information without charge.

3. Disclosure of the Client’s Information

3.1 The Company will keep the User’s personal data confidential but the User agrees that the Company may provide information to:

3.1.1 any member of the Company’s group, which means all subsidiaries, the Company’s ultimate holding company and its subsidiaries, as defined in Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the Law of Hong Kong;

3.1.2 personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with the Company’s operations or services (for example staff engaged in the fulfilment of the User’s order, the processing of the User’s payment and the provision of support services);

3.1.3 the Company’s overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);

3.1.4 persons under a duty of confidentiality to the Company;

3.1.5 persons to whom the Company is required to make disclosure under applicable laws and regulations in or outside of Hong Kong; or

3.1.6 actual or proposed transferees of the Company’s operations (or a substantial part thereof) in or outside of Hong Kong.

4. Cookies

4.1 The Site and/or the APP uses cookies to distinguish the User from other users of the Site and/or the APP. This helps the Company to provide the User with a good experience when the User browses the Site and/or the APP and also allows the Company to improve the Site and/or the APP.

4.2 A cookie is a small file of letters and numbers that is stored on the User's browser or the hard drive of the User’s computer if the User agrees to the use of cookies. Cookies contain information that is transferred to the User's computer's hard drive.

4.3 The Company may use third-party web services on the Site and/or the APP. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help the Company analyse how visitors use the Site and/or the APP and make the information displayed on it more relevant to the User's interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

5. Third-Party Sites

5.1 The Site or the Company’s communication with the User may from time to time contain links to third-party websites over which the Company has no control. If the User follows a link to any of these websites, please note that they have their own practices and policies. The Company encourages the User to read the privacy policies or statements of these websites to understand the User’s rights. The Company accepts no responsibility or liability for any practices of third-party websites.

6. Security

6.1 All information the User provides to the Company is stored on the Company’s secure servers.

6.2 The Company restricts access to personal information to Company employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.

6.3 The Company reviews the information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

6.4 Please note, however, the transmission of information via the Internet is not completely secure. Although the Company will do its best to protect the User's personal data, the Company cannot guarantee the security of the User’s data transmitted to the Site and/or the APP; any transmission is at the User’s own risk.

7. The User’s Rights

7.1 The User has the right to:

7.1.1 check whether the Company holds personal data about the User;

7.1.2 access any personal data the Company holds about the User; and

7.1.3 require the Company to correct any inaccuracy or error in any personal data held about the User.

7.2 Any request under Clause 7.1 may be subject to a small administrative fee to meet the Company’s cost in processing the request.

8. Changes to the Personal Information Collection Statement  

8.1 The Company may amend this Statement from time to time by posting the updated Statement on the Site and/or the APP. By continuing to use the Site after the changes come into effect means that the User agrees to be bound by the revised Statement.

9. Enquiries

9.1 If the User has any questions about this Statement, please contact us at 05-108, The Quayside, 77 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong or via dummy@chocfin.com.

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